The 2033 retrofit date, and the 12-year clock that replaced it.

For a few years every Maryland high-rise board heard the same date: January 1, 2033. The State Fire Marshal, acting on a State Fire Prevention Commission determination, had told owners that every residential high-rise in the state, condominiums and housing cooperatives included, had to be fully sprinklered by then. Reserve studies got rewritten. Some buildings started work. Then the rule went quiet, and most boards never got a clear account of what replaced it. Here it is.

The rule that applies today

Maryland adopts the NFPA 101 Life Safety Code, 2024 edition, as part of the State Fire Prevention Code. That edition does carry a January 1, 2033 date for sprinklers in existing high-rise apartment buildings. Maryland amended it. The General Assembly’s own fiscal note on HB 149 puts the current rule in one sentence: the State Fire Prevention Code “amended these provisions to instead require that all existing high-rise apartment buildings have installed automatic sprinkler systems, unless the building meets specified egress requirements, within 12 years of the date of the original violation notice issued by the fire authority having jurisdiction.”

So the clock is not a calendar date that every building in the state shares. It is 12 years, and it starts on the day your building’s own violation notice was issued. Two boards in the same county can have deadlines years apart. A board that has never been cited has no fixed date yet. A board that has been cited should find the original notice and read the date on it.

The egress exception is real but narrow. A building that already meets the code’s egress requirements for an unsprinklered high-rise can stay unsprinklered. Very few pre-1974 towers do, and the only way to know is to have the fire protection engineer check the building against the current chapter.

What a violation notice is, and who issues it

A violation notice is the written finding from a fire inspector that a building does not meet the State Fire Prevention Code. It usually arrives after a routine inspection or a complaint, names the section of the code, and gives a period to correct it. For an unsprinklered high-rise, the sprinkler finding is the one that starts the 12 years.

The notice comes from the fire authority having jurisdiction. In most of Maryland that is the county or city fire marshal. Under the Public Safety Article a county or municipality may designate its fire marshal or another fire official to serve as an assistant State fire marshal, and that person enforces the State fire code there. Where a jurisdiction has not designated one, the Office of the State Fire Marshal does the inspecting and issues the notice itself. The fiscal note spells out both cases. In practice, the letterhead on your notice tells you which office owns your file.

What the Fire Marshal said on January 29, 2024

Before the amendment, the Commission had made a general determination that every existing high-rise be retrofitted by the 2033 date. On January 29, 2024 the Office of the State Fire Marshal determined that this general determination will not be enforced. The date was not pushed back. The requirement was replaced with the per-building clock described above. For a building that has never received a notice, that means there is no statewide retrofit deadline running today.

We will not tell you January 1, 2033 is a statewide deadline, because it is not. Anyone who does tell you that is either reading an old notice or selling something. The date that matters is the one on your building’s own notice, plus 12 years.

What Montgomery County still says

Montgomery County runs its own existing high-rise sprinkler program under county law. As of February 2023 the county counted 76 high-rises without sprinklers in every unit. For scale, a state workgroup estimated in its June 2025 report that about 300 pre-1974 high-rise apartment buildings statewide are not fully sprinklered. The state’s 2024 decision did not touch the county ordinance. If your building is on that list, the county’s schedule is the one that governs, and the right move is to confirm the current deadline with Montgomery County Fire and Rescue in writing rather than relying on the state headline.

Other counties have not, to our knowledge, adopted a general existing-building retrofit rule. The City of Annapolis has a targeted one for about 50 Main Street and Francis Street buildings, which we cover on the Annapolis page.

What Chapter 422 does and does not change

In May 2026 the Governor signed HB 149 as Chapter 422, effective October 1, 2026. Some owners read it as the 2033 mandate coming back. It is not. The new rule reaches a residential rental high-rise that undergoes a substantial renovation, meaning permanent value-adding work costing 40 percent or more of SDAT assessed value, and only for permits issued on or after October 1, 2026. A building that is not renovating at that scale is not pulled in. The 12-year clock sits in the fire code, not in Chapter 422, and the two rules run separately. The full text is on our Chapter 422 explainer.

What boards should do now

1. Check the file for a violation notice. If the building has one, the date on it sets the deadline. If it has none, the clock has not started, and the board should know that in writing before it tells owners anything.
2. Find out which rules reach the building. State fire code, county ordinance, and city ordinance are three different things. Get a one-page memo from counsel or from us that names each one and says yes or no.
3. Test what you already own. Standpipes, fire pumps, and alarm panels in a 1960s or 1970s tower are usually the real cost driver, and they are needed whether or not sprinklers follow. A current test report is cheap and changes every later number.
4. Keep a sprinkler line in the reserve study. A notice can arrive any year. A board that dropped the line in 2024 and gets cited in 2027 will be funding a retrofit from special assessments. Our financing page has the language.
5. If a renovation is coming, price it against the 40 percent line first. The calculator gives the figure in a few seconds.